Privacy Policy

Effective Date: 31 October 2024

1. Introduction

Onerise (“we,” “our,” or “us”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website www.onerise.co, use our services, or interact with us in any way.

2. How Is Personal Information Collected?

Onerise usually collects your personal information in a number of ways including:

Directly from You: Such as when you provide the information by phone, email, in an application form, or an online form (e.g., sign-up form, signing up for newsletters, or downloading fund information material), or when you access a user account on our site, or when you participate in a survey, promotion, or competition.

From Other Onerise Group Companies: Where permitted by law.

From Policy Holders: If they have listed you as a beneficial owner or other related person in connection with the investment (e.g., a nominated beneficiary, reversionary, or an individual granted power of attorney) and have provided us with your name, date of birth, and contact details.

From Third Parties: Such as your financial adviser, platform provider, lawyer, or other agents or credit reporting agencies, credit providers, or identity verification service providers, if you authorize us to do so.

From Publicly or Commercially Available Sources: For the purpose of complying with customer due diligence obligations under relevant legislation (e.g., anti-money laundering laws).

3. What if You Do Not Provide Certain Information?

If you provide us with incomplete details on a contact form or application form (including answering questions to ensure you are likely to be within the target market for the product), we may not be able to provide you with the information, product, or service until you provide the details we require.

If you do not provide us with all relevant identity verification documents, or adequately satisfy electronic identity verification requirements, we may not be able to provide you, or continue to provide you with a product or service.

If you choose not to disclose your Tax File Number (TFN), TFN exemption, or Australian Business Number (ABN), we may have to deduct tax at the highest marginal rate (plus the Medicare levy) from distributions or income payments made to you. If you are a foreign tax resident and you have not provided us with information we have requested about your tax residency (i.e., your Tax Identification Number or similar number issued by the relevant foreign tax authority), we may not be able to process your request, or we may be required to notify the Australian Taxation Office (ATO).

If you choose not to disclose your account details or correctly answer verification questions, we may not be able to process the transactions you request or allow access to our online services.

4. How Do We Use and Disclose Your Personal Information?

Onerise may collect, use, and disclose your personal information for the primary purpose of providing the information, products, and/or services requested, as well as for related purposes such as:

Verification: To verify transaction requests or your identity (including the identities of third parties connected with your product/service application, such as beneficiaries and beneficial owners, where applicable).

Processing Applications: To process your applications for our products and services.

Administration: To administer and manage the provision of our products and services.

Customer Service: To respond to queries, complaints, or provide you with our general customer services.

Adviser or Agent Communication: To provide your nominated financial adviser or other agent with details of your investment.

Membership Confirmation: To confirm your membership of an association with which we have an affiliation.

Marketing: To provide you with updates and marketing material, including offers of other Onerise products or services, and to improve and personalize our products and services.

Compliance: To comply with laws and regulatory requirements, including anti-money laundering, financial services, and taxation laws, or complying with any request made by a governmental authority in connection with legal proceedings or the prevention or detection of fraud and crime.

Risk Management: To comply with Onerise’s risk management policies and procedures.

Research: To conduct product and market research.

Training: To train our staff.

Seamless Online Experience: To provide a seamless online experience and to provide you with control of your personal information and easy access to it.

Employment Applications: If applying for employment with Onerise, to complete appropriate background checks.

Office Visits: If attending our offices in person, to assist Onerise in providing a safe and secure environment for employees and visitors.

5. Who Do We Disclose Your Personal Information To?

We may disclose your personal information to:

Advisers and Agents: Your financial, legal, or other adviser, or your broker, agent, or platform provider.

Financial Institutions: With whom we have a branding arrangement.

Professional Service Providers: Professional service firms that provide services to us, such as legal, audit, data, and IT support/information services.

Identity Verification Providers: Electronic identity verification service providers, in order for identity information (about you or related persons connected with your investment) to be verified against relevant government and other databases, for the purpose of complying with anti-money laundering laws.

Reinsurers and Related Companies: Reinsurers or our related companies.

Associations: Organisations with which we have an association, and you are a member.

6. Keeping Us Up-to-Date

Personal information such as your contact details may change from time to time, and we ask that you keep us informed of any changes by notifying us. Where you have previously provided information about another person related to your investment (such as a beneficial owner, beneficiary, or reversionary) and the information is no longer current, you must provide up-to-date information.

Changes to some details, such as a change of name, may require additional documentation to verify the change. Additionally, some changes may be required to be made on a specific form (such as a change of bank account from which direct debits are deducted). Onerise is unable to change any account details through email. To change your contact information, please download and complete the Change of Details form.

7. Access and Correction

Generally, Onerise will provide you with access to your personal information that we hold, unless a particular exception applies, such as where:

It would be unlawful to provide the information;

Providing access would be likely to prejudice an investigation of possible unlawful activity;

The information is relevant to legal proceedings and would not be accessible in the normal discovery process;

Giving access would have an unreasonable impact on the privacy of other individuals;

It would pose a serious and imminent threat to the life or health of any individual; or

The request is frivolous or vexatious.

If a request for access would divulge a commercially sensitive decision-making process, then Onerise may provide an explanation rather than direct access to the information.

If we become aware that the personal information we hold about you is inaccurate, incomplete, misleading, or irrelevant, then we will take reasonable steps to amend it. If we receive a request from you to correct your information, then we will seek to correct it within 30 days. If you and Onerise disagree about the accuracy, completeness, or currency of our records, then you have the right to request that we note your disagreement on those records.

8. Anonymity and Pseudonymity

Given legal requirements on financial institutions to identify their customers, in most situations, Onerise is unable to allow you to transact with it on the basis of anonymity (including the use of a pseudonym). Access to the Onerise public website and some other interactions with Onerise may be done anonymously, or in the case of general inquiries, using a pseudonym. However, we may not be able to respond to your queries unless you provide us with certain information.

9. Direct Marketing

Onerise will not use your personal information for direct marketing purposes unless:

• We have obtained your consent or you would reasonably expect us to use your personal information for direct marketing purposes; and
• We have provided you with a simple means to “opt-out” from receiving direct marketing; and
• We have not received an opt-out request from you.

Onerise will not use any sensitive information collected from you for direct marketing purposes. To opt out of receiving direct marketing, please contact us (see ‘Contacting Us’ section of this policy).

10. Use of Our Website

We will collect some information from you when you visit the Onerise website or use the Online Investor Portal. Your use of the facilities and services available through the website will determine the amount and type of information that we will collect about you. Some of this information will not be personal information because it will not reveal your identity.

The only personal information we collect about you when you use the website is what you tell us about yourself; for example, by completing an online form such as an application form, providing account instructions online, changing your personal or contact details, asking for a Product Disclosure Statement (PDS), signing up for our email communications, or sending us an email. When you access a user account, we may subsequently collect information about your use of the website. This may be used to ‘personalize’ your experience on the website by displaying content that is likely to be relevant to you. This information may also be used to help us understand whether you may benefit from additional support (e.g., we may contact you to determine whether you need assistance in finalizing or progressing incomplete applications or quotes).

11. Login Site & User Accounts

If you access an online account, cookies may also store information related to your session and visit duration, which can be linked back to your login identification. For more information on cookies, please refer to the ‘Cookies’ section below.

Because access to user accounts is restricted to users with an account, you will be required to use your secure login. Unique identifiers (such as your login identification) are collected from website visitors to verify the user’s identity.

Unique identifiers may also be used to store information about preferences, to enable dynamic display of the website according to your preferences when you return.

Onerise uses the data collected for statistical analysis and business purposes. We may also use your personal information to contact you via email or phone to tell you about other products or services that we think may be of interest to you, or seek feedback relating to improving the customer experience. If you do not wish to be contacted for these purposes, you can opt-out by contacting us (see the ‘Contacting Us’ section of this policy). The data is accessible only to authorized Onerise employees. Information which is automatically collected may be published internally as aggregated (de-identified) information to assist with improving the products and services offered by Onerise.

12. Website Analytics

Onerise uses third-party tracking tools to collect information on how people use our website and to help us segment customers for certain marketing activities. Our third-party tracking tool providers use “cookies” and in some cases “clear gifs/web beacons” to collect information. Examples of data collected include page views, button clicks, IP address, ISP, errors, device, device OS, and browser.

13. Online Advertising

Onerise uses several advertising companies for our online advertising. These advertising companies may use cookies to collect information such as browser type, date and time of your visit, your interactions with banner advertisements, and if you have visited our website through an online advertisement. None of the information collected by the advertising companies will personally identify you.

Onerise uses the Google Marketing Platform to display advertising based on what parts of the Onerise website have been visited by placing a cookie on your machine. This cookie does not identify you as an individual and allows us to tailor our marketing to better suit your online activity and display ads that are relevant to you. Visit Google’s Privacy Policy for more information on the Google Marketing Platform cookie and how to opt-out from the use of these cookies.

Onerise uses the Facebook Pixel and the LinkedIn Insight Tag to enable in-depth campaign reporting and to help us unlock valuable insights about our website visitors. We use both the Facebook Pixel and the LinkedIn Insight Tag to track conversions, retarget website visitors, and unlock additional insights about Facebook and LinkedIn members interacting with our Facebook and LinkedIn adverts.

Both the Facebook Pixel and the LinkedIn Insight Tag enable the collection of metadata such as IP address information, timestamp, and events such as page views. All data is encrypted, and Onerise is unable to identify you and will not attempt to identify you at any point. Onerise may share metadata collected via the Facebook Pixel with Facebook, and metadata collected via the LinkedIn Insight Tag with LinkedIn. Facebook or LinkedIn may then be able to identify you using the Facebook or LinkedIn browser cookie.

14. Cookies

Cookies are pieces of information that are transferred to your computer when you visit a website so that sites can record usage and, in some cases, provide you with tailored content or targeted advertising. Most web browsers are set to accept cookies. You can choose to disallow cookies by changing settings on your web browser. However, if you reject all cookies, you may not be able to use some areas of our websites.

15. Electronic Verification

We are required by the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 to verify your identity before we can provide you with financial products and services. We may need to verify your identity electronically if the copies of the identity documents you provide have not been certified or if we need to perform any additional checks to meet our legal requirements.

How Electronic Verification Works

To verify your identity electronically, we will pass certain information to official State and Commonwealth record holders via our service provider to electronically match your information with information on their databases. These organisations will compare the information to their records and confirm whether all or some of the information you provided matches their records.

What Information Will Be Shared and Who Will It Be Shared With

If we need to verify your identity electronically, we will provide the following information to our service provider:

• Full name
• Date of birth
• Residential address
• Government identifiers such as your passport or driver’s license number.

We have engaged GreenID to check the relevant identity document details you have provided against the records held by the government authority that issued it (either via the government’s Document Verification Service or directly with the relevant issuer) and to check the document is valid and has not expired.

16. Complaints About Your Privacy

If you wish to raise any concerns about any breach or potential breach of your privacy, please contact our Privacy Officer and we will make every effort to resolve your complaint internally. If you wish to raise a concern, you should be aware of the following:

• Your complaint should be made in writing to the Privacy Officer (via post or email).
• We will attempt to respond within 30 days from receipt of your request.
• If you feel your concerns have not been resolved, the complaint may be taken to the Office of the Australian Information Commissioner (OAIC).
• Alternatively, you may also take the complaint to an external dispute resolution service, such as the Australian Financial Complaints Authority (AFCA).

AFCA provides fair and independent financial services complaint resolution that is free to consumers. There are some time limits for lodging certain complaints; please consult the AFCA website to find out if or when the time limit relevant to your circumstances expires.

For more information on how you may lodge a complaint with the OAIC, please contact the OAIC hotline service on 1300 363 992 or email enquiries@oaic.gov.au. Alternatively, AFCA may be contacted at 1800 931 678 or info@afca.org.au.

17. Changes to Our Privacy Policy

Onerise may make changes to this policy from time to time for any reason and we will update the website in a timely manner.

18. Contacting Us

If you would like more information about how we manage your personal information, our team is available Monday to Friday, from 9am to 5pm EST, and can be contacted on +61 2 7228 5528. Alternatively, you can write to us at the following address:

The Privacy Officer
Level 9, 50 Clarence Street
Sydney NSW 2000
Australia

Or send an email to: privacy@onerise.co.